DEFENDANT’S FIRST SET OF INTERROGATORIES
The plaintiffs in case no. 04 L 3381, through their attorneys, requests plaintiff in
that case, pursuant to the Rules of the Supreme Court of Illinois, to respond to the
following discovery requests under oath within 28 days.
For the purpose of these discovery requests, the following definitions shall apply:
(a) Unless otherwise specified, the time period referenced in these interrogatories
is January 1, 2000 through the present.
(b) "Identify," when used with respect to an individual, means to state the
person's full name, social security number, last known telephone number and home
address, present business affiliation and position or job title, if known.
(c) "Plaintiff" means or refers to Our Lady of the Resurrection Medical Center
(hereafter “Our Lady”).
(e) “Defendants” refers to Phyllis Servedio, Juan Nieto, Wieslawa Starzyk, and
(f) "Identify," when used with respect to a document, means to state the date,
author, addressee, type of document (e.g., letter), date document obtained, and to identify
its last known custodian and location.
(g) “Document” means writings or recordings of every kind and description
whether made by hand, mechanical, electronic, microfilm, photographic or other means.
It includes information generated by or stored in a computer.
(h) “Patient” refers to inpatient services at Our Lady.
(i) If plaintiff declines to produce any document or fails to respond to an
interrogatory due to a claim of privilege, please (1) identify the subject matter (e.g. letter,
memorandum), date, and author of the privileged communication or information, and all
recipients; (2) identify those persons to whom the contents of each alleged privileged
communication or document has been disclosed; (3) state what privilege is claimed; and
(4) state the basis upon which the privilege is claimed.
(j) If any document requested was, but no longer is, in defendant’s possession or
subject to defendant’s control, state: (1) date of its disposition; (2) the manner (e.g. lost,
destroyed, etc); and (3) explain the circumstances leading to the disposition of the
(k) Please supplement all answers and documents produced in the future if
additional information is obtained or if additional documents related to these discovery
(l) “Chargemaster” means a list(s) of standard gross charges at Our Lady for
items of medical services, supplies, medications, etc.
1. State the amount of revenue (in dollars) Our Lady received for providing
medical services each year, beginning 2000 through 2004, from (a) third-party payors
excluding Medicaid and Medicare; (b) Medicaid; (c) Medicare; (d) Uninsured patients;
(e) self-payors other than the uninsured; and (f) others.
2. State, for each year from 2000through 2004, the percentage of patients (a)
who are required to pay the full amount of the hospital’s chargemaster charges; (b) whose
bills are paid by Medicare; (c) whose bills are paid by Medicaid; (d) who receive
discounts by virtue of agreements with third-party payors; and (e) who receive charitable
write-offs or discounts. If there are other significant categories, identify them as well and
state the percentages for these categories.
3. For each hospitalization of the defendants, state the amount of the bill
rendered to them and the actual costs to Our Lady of such services.
4. For every hospital bill rendered to the defendants, state the actual amount
Our Lady would have accepted to pay each bill in full had the defendant been insured by:
c) Health Care Service Corp.;
d) Health Care Service Corp. Mutual Legal Reserve Co.; and
e) Unicare Health Insurance Co. of the Midwest.
5. Identify and describe the agreements between Our Lady (or Resurrection
Health Care) and Health Care Service Corp., Blue Cross, Health Care Service Corp.
Mutual Legal Reserve Co., Unicare Health Insurance Co. of the Midwest between 2000
and 2004 that were used for determining the discounted charges for services rendered at
6. Please identify any written charge comparisons between defendant and
other similarly situated hospitals for the relevant time period.
7. Please identify the person(s) responsible for setting Our Lady’s charges
and the persons who negotiate discounted charges to third party payors.
8. Identify the agent of Our Lady who has knowledge of the hospital's
practice of discounting charges for third-party payors other than Medicare and Medicaid.
9. Identify the agent or agents of Our Lady who has knowledge of the
reasonable value and actual cost to plaintiffs of the goods, procedures and services for
which defendants were billed.
10. Identify the witnesses and all opinion witnesses of Our Lady who will
testify for the plaintiff at trial and state the matters that they will address in their